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The G-20's Financial Stability Board is seeking comment on a proposal to add insurers to the list of financial institutions affected by guidelines designed to address the issue of companies being "too big to fail."

In a document titled, "Key Attributes of Effective Resolution Regimes for Financial Institutions," the FSB outlines three areas that should be addressed by proposed solutions to the "too big to fail problem." The FSB's proposed guidelines cover the resolution of the financial market infrastructure, the resolution of insurers and the protection of client assets.

The FSB has asked the financial services industry to weigh in on proposals to apply the guidelines to non-bank financial institutions, including insurers. The FSB is also seeking comment on proposed principles for governing information-sharing for resolution purposes.

Comments must be submitted by Oct. 15.

The FSB said "Key Attributes" are a significant piece of the FSBs' policy framework to address the moral hazard and systemic risks associated with institution that are "too big to fail." They were originally released by the FSB in November 2011, following their endorsement by G-20 Leaders at the Cannes Summit.

"They set out the core elements considered necessary to make feasible the resolution of financial institutions without severe systemic disruption and without exposing taxpayers to loss," the FSB statement said. "They constitute an 'umbrella' standard that applies for all parts of the financial sector that could cause systemic problems."

The guidelines for insurers are designed to build upon the policy measures for global systemically important insurers published by the International Association of Insurance Supervisors on July 18, which include recovery and resolution planning requirements for G-SIIs.

At the time, the FSB also released its initial list of nine companies that have been designated as G-SIIs.

The companies included on the list will face additional regulatory oversight and more stringent capital requirements. But those requirements won't be spelled out by the IAIS until the G-20's Summit next year. Implementation details for higher capital requirements will be developed by the end of 2015. The requirements will apply starting in January 2019 to G-SIIs identified as of November 2017, the FSB said in a July 18 announcement.

The initial list included Allianz SE; American International Group, Inc.; Assicurazioni Generali S.p.A.; Aviva plc; Axa S.A.; Metropolitan Life Insurance Co. Inc.; Ping An Insurance Company of China, Ltd.; Prudential Financial Inc.; and Prudential plc. But the FSB's time line for implementing the new regulatory requirements hints that more companies could be added to the list at a later date.